Privacy Policy

This Privacy Notice sets out what personal information we may collect from you and how that information may be used. In particular, this Privacy Notice explains:

How we will manage your personal information, from the time we collect it and onwards;
How we use your personal information and who we share it with;
How we will comply with any relevant laws; and
Your rights in relation to your personal data, and how you can exercise them.

This Privacy Notice does not cover any links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies.

When you leave our websites, we encourage you to read the privacy policy of any website you visit.

About Us

SpinePro Limited (SpinePro) is an independent agent for the UK & Channel Islands, promoting treatment to private patients that is normally delivered by European healthcare providers. In order to provide services and receive payment for those services, SpinePro needs to collect and process certain information about you (“personal data”).

SpinePro is a ‘data controller’ for the information that it collects and processes. Our Data Protection Officer can be contacted at info@spinepro.uk

SpinePro is committed to protecting and respecting your personal information.

This Privacy Notice explains what personal information we may collect from you and how that information may be used. Please take your time to read this Privacy Notice carefully.

Personal Information

We will use your personal data for the reasons set out below.

Personal Data

Your name, address and contact details, including email address and home and mobile telephone numbers. If you provide these details, we may use them to contact you unless you ask us not to. This could include emails, text or voicemail messages;
Date of birth and gender;

Contractual and Financial Information

The terms and conditions of your contract with us for the provision of healthcare and related services;
Your bank account or the financial information of the company or individual who is responsible for the payment of invoices;
Data relating to your care (e.g. insurer, sponsor, guarantor or employer);
Information about your marital status, next of kin, dependants nominated and / or emergency contacts;

Health related Data

Your previous and current medical health records;
Information about medical or health conditions, including whether or not you have a disability for which the organisation needs to make reasonable adjustments;
Information about medical or health conditions of your family;

Performance Improvement

Information about how you use our website.

Information received in response to any surveys & complaints claims

CCTV

The data we collect may also include visual images, personal appearance and behaviour e.g. where CCTV is used as part of our building security measures.

Data Collection

SpinePro collects information in a variety of ways.

We will collect most of this information directly during the registration and / or admission process but we may also obtain data from;

Your passport or other identity documents such as your driving licence;
Pre-admission forms & online web forms;
From correspondence with you;
Interviews and surveys, meetings or other assessments.

We will collect data if you have a remote consultation with a healthcare professional either virtually or by telephone.

If we ask you to provide copies of your medical records we will retain these for six months unless we go on to provide clinical care for you in which case your records will be held in accordance with our normal retention policy.

We will tell you if providing some personal data is optional, including if we need to ask for your consent to process it.

In all other cases, we need you to provide your personal data so we can provide care and treatment to you and receive payment for these services.

Use of Personal Data

We use your personal data to support the provision of our services in the following ways:

To decide how best to provide treatment to you;
As necessary to contract with you and to allow us to receive full payment for those services;
To take steps at your request during the course of your treatment;
To keep your records up to date

We use your data for the following purposes, to maintain the high standards of service that we provide to you:

For good governance, accounting, and managing and auditing our clinical and business operations both internally and by third parties;
For surveys of patient experience and quality of care;
To monitor emails, calls, other communications, and activities on our networks and systems;
For market research, other surveys and analysis and developing statistics for improving clinical performance; and

We may process your data to ensure the security of our systems and to prevent crime and ensure compliance with all laws and regulations that are applicable to our services.

We may monitor and record telephone calls, emails, text messages, social media messages and other communications in relation to our dealings with you. We will do this to ensure an appropriate standard of care, for regulatory compliance, self-regulatory practices, crime prevention and detection, to protect the security of our communications networks and systems, to check for unlawful content, obscene or profane content, for quality control and staff training, and when we need to see a record of what has been said.

We may also monitor activities on our network and systems where necessary for these reasons and this is for our legitimate interests or other legal obligations.

We use your data to ensure we can comply with our legal obligations:

When you exercise your rights under data protection law and make requests;
For compliance with legal and regulatory requirements and related disclosures;
For establishment and defence of legal rights;
For activities relating to the prevention, detection and investigation of crime;
To verify your identity, credit fraud prevention and anti-money laundering checks; and
To investigate complaints, legal claims and data protection or clinical incidents.

Based on your consent we may also share your data:

With your next of kin or other nominated contact;
If you ask us to disclose your personal data to other people or organisations or otherwise agree to disclosures;
When we process any special categories of personal data about you at your request (e.g. racial or ethnic origin, religious or philosophical beliefs, genetic data, biometric data, data concerning your health, sex life or sexual orientation).

You are free at any time to change your mind and withdraw your consent, where we have only relied on your consent, to share your data. We will advise you if the consequence of doing so is that we cannot continue to provide services to you.

Data Sharing

We may share your personal data with:

Healthcare affiliates or those whose services we provide to you

Doctors, Consultants and other Healthcare Professionals who provide treatment to you;
Other healthcare providers including your General Practitioner (GP) where we believe this will enhance the quality of your care;
Companies, sub-contractors and other persons who help us to provide services to you;
Advisors, Legal, Government and regulatory bodies;

Legal and other professional advisors

Fraud prevention agencies, credit reference agencies, and debt collection agencies;
Government bodies and agencies in the UK and overseas; General Medical Council and other professional bodies;
Courts, to comply with legal requirements, and for the administration of justice;

Others

In an emergency or to otherwise protect your vital interests;
Third parties who help us to protect the security or integrity of our business operations and other patients;
Payment systems and providers; and
Anyone else where we have your consent or as required by law.

Sharing of your personal data in order to receive payment

We will contact the individual or company and provide them with the information necessary to support our invoices for payment and to ensure that we receive full payment for your care.

We may also contact them prior to your care to confirm that they are willing to pay for your care.

Marketing Activities

Subject to obtaining your consent and in accordance with your communications preferences we may use your contact details to send you newsletters and other information on new services and treatments which we think may be of interest to you.

We will not sell your personal data to a third party without your written consent.

You are free at any time to withdraw consent for marketing activities. Please contact info@spinepro.uk. This will not affect the healthcare services we provide to you.

Data Retention Period

Information will be kept in accordance with the retention periods outlined in the Information Governance Alliance (IGA) Records Management Code of Practice for Health and Social Care (2016).

Information may be held for longer periods where the following apply:

Retention in case of queries – We will retain your personal data as long as necessary to deal with any queries you may have;
Retention in case of claims – We will retain your personal data for as long as you might legally bring claims against us; and
Retention in accordance with legal and regulatory requirements.

Your rights under applicable data protection law

Your rights under data protection laws are as follows (noting that these rights do not apply in all circumstances):

The right to be informed about processing of your personal data;
The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed;
The right to object to processing of your personal data;
The right to restrict processing of your personal data;
The right to have your personal data erased (the “right to be forgotten”);
The right to request access to your personal data and information about how we process it;
The right to move, copy or transfer your personal data (“data portability”) ; and
Rights in relation to automated decision-making including profiling

You may exercise these rights by contacting us on info@spinepro.uk

You have the right to complain to the Information Commissioner’s Office (ICO). It has enforcement powers and can investigate compliance with data protection law.

Contact the ICO on www.ico.org.uk.